DE: Stripping Operation Violates Law

An aircraft painting contractor accused of providing "inconsistent" answers regarding its waste practices and operating a paint-stripping operation unlawfully is facing multiple violations and a major fine from the State of Delaware.

Delaware's Department of Natural Resources and Environmental Control has imposed a fine of $81,426 and $12,214 in cost recovery against Summit Aviation Inc., of Middletown, DE.

The agency's order was issued Friday (Jan. 10), three and a half months after an inspection of the company's facility turned up issued 18 violations of Delaware's hazardous-waste regulations.

The department also said that Summit's answers to some of the state's questions had been "inconsistent."

About the Company

Founded in 1960, Summit provides aircraft and aviation painting, repair and maintenance services for U.S. and foreign governments, corporate and private customers. Summit is one of 10 aviation services companies owned by Greenwich AeroGroup, which was established in 2007.

In 2011, Summit completed a 78,000-square-foot facility expansion that includes a new paint facility and 37,400-square-foot hangar. The operation sits on a 550-acre site, and the facility is Defense Investigative Serivce (DIS) approved Top Secret, according to the company's website.

Summit did not reply Monday (Jan. 13) to a request for comment.

Paint Stripping Violations

The state has been working with Summit for two years on "conducting paint stripping operations via the installation of a hazardous waste tank system," according to the DNREC order.

Greenwich AeroGroup

Founded in 1960, Summit Aviation is one of 10 aviation service companies now owned by Greenwich AeroGroup, which was formed in 2007.

However, as of October 2013, Summit told the agency that it had not installed the system but "had elected to commence paint stripping operations."

Meanwhile, until 2012, Summit identified itself as a "conditionally exempt small quantity generator" of hazardous waste when it was, in fact, a "large quantity generator."

State inspectors determined that the facility had conducted "five paint stripping events" in its paint hangar "without having the appropriate paint stripping operation system in place."

Furthermore, the order says, Summit told the agency in a letter Oct. 3 that it had had three paint stripping events; several weeks later, in another letter, it reported five stripping events.

Sheeting System

Summit said that its paint-stripping building "has concrete curbing around the exterior to prevent waste from being released from the building," according to the order. Summit also said that it covered the facility's floor, including floor grates, with two layers of 4 mil poly sheeting.

Aircraft are rolled into the hangar onto the sheeting, and the paint stripper is pumped on and squeegeed off. The sheeting is then placed into drums labeled as hazardous waste.

Summit Aviation

Summit Aviation is accused of operating its painting hangar in violation of Delaware environmental law.

The state has told Summit that the system is unacceptable. In April 2012, a consultant for Summit asked to use a trench and aboveground storage tank to collect the hazardous waste from paint stripping.

The company said at that time that paint stripping had not yet begun. In May 2012, DNREC rejected Summit's plan, saying it "did not adequately meeting the secondary containment requirements for tank systems."

Jumping the Gun

The company submitted proposals twice more, but eventually started stripping operations without awaiting DNREC approval of either plan, the order says.

"In the absence of a hazardous waste tank system in place, Respondent is operating the paint hangar as a hazardous waste containment building in violation of" Delaware state law, the order says.

Other Violations

The order also accuses Summit of:

Mislabeling drums of hazardous paint waste as "non-regulated";

Failing to post no-smoking signs around ignitable toxic chemicals;

Failing to make adequate hazardous waste determinations;

Failing to provide any information regarding the management of aerosol paint waste;

Inability to identify the type of contamination on used rags stored in seven 10-gallon cans;

Leaving out open containers of used oil, solvent and waste paint;

Lacking a universal waste accumulation area and throwing fluorescent and other mercury vapor lamps in the regular trash;